(EU) 2023/1542 · Annex XIII(1)(s) -> Article 74(1)(e)
Meaning of battery labels: the explanation must match what is printed
This field does not ask for the label but for its meaning — explanatory text about what the reader can see on the battery. It covers labels and symbols in accordance with Article 13, or printed on the packaging or set out in the documents accompanying the battery, which is wider than Article 13 alone. The difficulty is timing: individual markings become mandatory on different dates, and one of those dates is not absolute at all. An explanation written today can easily describe a marking the product does not yet carry.
What is actually being explained
Point (e) reaches three sources at once: labels and symbols under Article 13, printing on the packaging, and statements in the accompanying documents. If you limited the content to what is physically on the housing, you dropped two of the three. That matters for small cells, because part of the Article 13 marking lawfully moves onto the packaging.
The separate collection symbol
Article 13(4): from 18 August 2025 all batteries must be marked with the separate collection symbol shown in Part B of Annex VI. The symbol covers at least 3 % of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. For cylindrical cells it covers at least 1,5 % of the surface area, again up to 5 × 5 cm. Where the symbol would be smaller than 0,47 × 0,47 cm, the battery need not be marked — instead a symbol of at least 1 × 1 cm is printed on the packaging.
Cadmium and lead
Article 13(5): batteries containing more than 0,002 % cadmium or more than 0,004 % lead must be marked with the chemical symbol for the metal concerned, Cd or Pb. It is printed beneath the separate collection symbol and covers an area of at least one quarter of that symbol's size. Those two thresholds are often misquoted or left out, even though they are exactly what the explanation is supposed to convey.
The Annex VI Part A label and the QR code
Article 13(1) to (3) ties the general information label in Part A of Annex VI, the capacity label and the non-rechargeable label to 18 August 2026 or 18 months after the entry into force of the implementing act referred to in Article 13(10), whichever is the latest. No absolute date can be stated here. The QR code is different: Article 13(6) requires it from 18 February 2027, as described in Part C of Annex VI — and for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries that code is what leads to the passport.
The explanation is model-specific
A battery placed on the market before a given date lawfully does not carry the marking. If your text explains a label this model does not have yet, you have described something the reader cannot see — and conversely, if you explain only the crossed-out wheeled bin, you have left out everything else. Verify the explanation against the actual production artwork for the model, not against the design intent.
Where it goes wrong
- Explaining a marking the battery does not yet carry.
- Stating an absolute date for the Annex VI Part A label, although Article 13(1) also ties it to the implementing act under Article 13(10).
- Omitting or misquoting the 0,002 % cadmium and 0,004 % lead thresholds.
- Explaining only the separate collection symbol and none of the other markings or accompanying documents.
- The same explanatory text for every model regardless of chemistry and cell format.
Frequently asked
From when must a battery carry the separate collection symbol?
From 18 August 2025 under Article 13(4), as shown in Part B of Annex VI. Where the symbol would be smaller than 0,47 × 0,47 cm it goes on the packaging instead, at a size of at least 1 × 1 cm.
When does the Annex VI Part A general information label become mandatory?
Article 13(1) sets 18 August 2026 or 18 months after the implementing act referred to in Article 13(10) enters into force, whichever is the latest. An absolute date therefore cannot be stated.
Do I have to explain markings on the packaging too?
Yes. Point (e) expressly covers symbols printed on the packaging and statements in the documents accompanying the battery, not only markings on the housing.
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